MEMORANDUM OPINION
MAHON, District Judge.
In this tax refund action tried to the Court, plaintiff as successor Independent Executor of the Estate of Mary Lard seeks the recovery of federal estate taxes paid in the amount of $337,780.00 pursuant to 28 U.S.C. § 1346.
The decedent, a Texas resident died testate on March 5, 1968. Her last will dated August 3, 1966, and two codicils to that will were duly probated. The will and codicils were admitted...
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